Webster Valve, Inc. 

South Main Street 

Franklin, NH 03235 

l 

l 

l 

l 

FINAL RACT ORDER 

March 21, 2007 

ARD07-001 

____________ ] 

A. Introduction 

This RACT Order is issued by the New Hampshire Department of Environmental Services, Air 

Resources Division, t6 Webster Valve, Inc., pursuant to RSA 125-C. 

B. Parties 

1. The New Hampshire Department of Environmental Services, Air Resources Division (DES), is 

a duly constituted administrative agency of the State of New Hampshire having its principal 

offices at 29 Hazen Drive, Concord, NH 03302, telephone number (603) 271-1370. 

2. Webster Valve, Inc. (Webster Valve) is a New Hampshire corporation doing business at the 

mailing address of South Main Street, Franklin, NH 03235, telephone number (603) 934-1327. 

C. Statements of Fact and Law 

1. Webster Valve owns and operates a facility located on South Main Street in Franklin, NH 

primarily engaged in the manufacturing of valves, regulators and backflow prevention devices 

for plumbing and heating and water quality applications. Operations at the facility include 

coating of the metal parts in one of six spray booths. 

2. Effective December 31, 2002, DES re-adopted the New Hampshire Code of Administrative 

Rules Env~A 1204, Stationary Sources of Volatile Organic Compounds (VOCs) with 

amendments. This part defines the sources that are subject to Reasonably Available Control 

Technology (RACT) requirements and specifies the RACT requirements. 

3. Webster Valve is subject to Env-A 1204.15, Applicability Criteria and Compliance Standards 

for Coating of Miscellaneous Metal Parts and Products, because the theoretical potential to emit 

(TPE) exceeds l 0 tons of non-exempt VOCs during any consecutive 12-month period. 

4. Webster Valve submitted a VOC RACT compliance plan on October 26, 1994 stating that a 

regenerative thermal oxidizer (RTO) along with emissions averaging would be used to comply 

with the requirements ofEnv-A 1204.15. 

5. On April25, 2001, Webster Valve submitted a modified VOC RACT compliance plan, 

proposing to discontinue the use of the RTO and use Discrete Emission Reductions (DERs) to 

. comply with the requirements of Env-A 1204.15. 

6. On May 21, 2001, Webster Valve acquired 120 DERs (60 ozone season DERs and 60 nonozone season DERs) from Public Service ofNew Hampshire, as generated in accordance with 

the federally enforceable RACT Order No. ARD-98-00 1, approved as part of the State 

Implementation Plan in the Federal Register Volume 65, page 68078 dated November 14,2000. 

7. On May 24, 2001, DES approved Webster Valve's modified VOC RACT compliance plan. 
RACT Order No. ARD07-001 

Webster Valve, Inc. 

March 21, 2007 

Page 2 of6 

8. State Permit to Operate, FP-S-0167 was issued on October 24,2001 to Webster Valve. 

Condition V.B of the permit allows Webster Valve to use DERs to complywithVOC RACT 

requirements. 

9. On June 23,2006, Webster Valve submitted an application to renew State Permit to Operate, 

FP-S-0167. This application also serves as the application to obtain a VOC RACT Order for the 

use ofDERs for compliance. 

D. Order 

Based on the statements offact and law, DES hereby orders Webster Valve, effective upon issuance 

of this Order, to comply with the following requirements as RACT: 

1. Coating of Miscellaneous Metal Parts and Products under Env-A 1204.15: 

a. For those processes applying a protective, decorative or functional coating onto metal parts 

and products, Webster Valve shall comply with the following emission limits for each 

coating used. All limits are in units of pounds of VOC per gallon of coating, as applied, 

excluding water and exempt compounds. Emissions in excess of these limits shall be offset 

by the use ofDERs in accordance with PartE below: 

(i) For a coating that is a clear or transparent top coat, as defined in Env-A 1204.03, 4.3 lbs 

VOC/gal coating; 

(ii) For a coating that is used in extreme environmental conditions, as defmed in 

Env-A 1204.15, 3.5 lbs VOC/gal coating; 

(iii) For a coating that is air dried, as defined in Env-A 1204.15, 3.5 lbs VOC/gal coating; 

and 

(iv) For all other coatings, 3.0 lbs VOC/gal coating. 

b. If more than one emission limit in D .l.a applies to a specific coating, then the least stringent 

emission limitation shall be applied. 

2. Calculation of Emission Standard On a Solids Basis 

For determining the amount ofDERs to be used in accordance with PartE below, the emission 

rate limit shall be determined on a solids basis, as specified below: 

(i) "S" means the VOC emission standard in terms of pounds VOC per gallon of coating 

solids; 

(ii) "Ec" means the VOC emission limit as stated in Part D.l, above; and 

(iii) "dA" means the actual mass density of the VOC in the applied surface coating 

formulation in terms of lb VOC/gal VOC; and 

(iv) S shall be equal to Ec divided by the difference between one and the quotient ofEc and 

dA, as in the following equation: 
RACT Order No. ARDOl-001 

Webster Valve, Inc. 

3. Calculation of Allowable VOC Emissions per Coating 

The allowable VOC emissions shall be calculated for each coating as follows: 

March 21, 2007 

Page 3 of6 

(i) "Eat means the allowable VOC emission rate of a given coating in units of lb/month or 

kg/month; 

(i) "S" means the VOC emission standard in terms oflb VOC/gal or kg VOC/1 of coating 

solids, as calculated in Part D .2, above; 

(ii) "W" means the weight of coating or dilution solvent used in the coating line on a given 

day in units of lb/month or kg/month; 

(iii) "D" means the density of the coating or dilution solvent in units oflb/gal coating, or 

kg/! coating as determined from Method 24 or 24A analysis; 

(iv) "VS" means the volume fraction solids content of the coating, in units of gal solids/gal 

coating or I solids/1 coating as determined by calculation using the formulation; and 

(v)" Eat" shall be equal to the product of S, VS and W divided by D for each coating or 

dilution solvent used, as in the following equation: 

Eat= S*VS*(W/D) 

4. Calculation of Actual VOC Emissions per Coating 

The VOC emissions shall be calculated for each coating as follows: 

(i) "Eac" means the actual VOC emission rate of a given coating in units of lb/month; 

(ii) "W" means the weight of coating or dilution solvent used in the coating line on a given 

day in units of lb/month; 

(iii) "WV" means the weight fraction ofVOC content of the coating, in units oflb VOC/lb 

coating as determined by calculation using the formulation; and 

(iv) "Eac" shall be equal to the product ofW and WV, as in the following equation: 

Eac=·W*WV 

5. Calculation of Excess Emissions per Coating 

The amount ofVOC emissions emitted in excess of the applicable limit for each coating shall be 

equal to the difference between the actual VOC emission rate (Eac) from the allowable VOC 

emission rate CEat). 

If the calculated excess emission rate is a negative number, no additional calculation is required. 

If the calculated excess emission rate is a positive number, the excess emission rate shall be 

divided by an environmental benefit factor of0.9. 

6. Demonstration of Compliance 

Webster Valve shall either test all coatings using the Methods described below, or retain 

sufficient records for prima facie evidence in support of demonstrating compliance with the 

VOC RACT limit. 

a. Method 24, 40 CFR Part 60, Appendix A at 1-hour bake time, or an alternative test method 

approved by the Director and EPA; or 
RACTOrder No. ARD07-00J 

Webster Valve, Inc. 

March 21, 2007 

Page 4 Of6 

b. Method 24A, 40 CFR Part 60, Appendix A, or an alternative test method approved by the 

Director and EPA. 

Prima facie evidence shall include all of the information required by the VOC data sheet found 

on either page II-2 or ill-2, as applicable, of EPA document EPA-450/3-84-019, Procedures for 

CertifYing Quantity of Volatile Organic Compounds Emitted by Paint, Ink, and Other Coatings, 

dated 1984. 

If there is a discrepancy between the formulation data and the results of the Method 24 or 24A 

analysis, compliance shall be based on the results from the Method 24 or 24A analysis. 

7. Recordkeeping Requirements 

Webster Valve shall maintain the following records in order to demonstrate compliance with 

this order. Each record shall be kept for a period of at least five years. 

a. Records of tests conducted pursuant to Part D.5, above. 

b. Records of prima facie evidence gathered pursuant to Part D.5, above. 

c. Records required to be maintained pursuant to Env-A 904, VOC Emission Statements 

Recordkeeping Requirements, except that actual VOC emissions shall be recorded on a 

monthly basis instead of an armual basis. 

8. Reporting Requirements 

Webster Valve shall submit the following reports: 

a. Emission reports in accordance with Env-A 908, VOC Emission Statements Reporting 

Requirements; and 

b. Discrete Emissions Reductions reports in accordance with Part E. 

E. Emissions Reductions Credits 

1. Webster Valve shall be allowed to use discrete emissions reductions (DERs) for the purpose of 

satisfying the requirements of this Order by acquiring DERs from Public Service of New 

Hampshire, as generated in accordance with the federally enforceable RACT Order No. 

ARD-98-00 1, approved as part of the State Implementation Plan in the Federal Register Volume 

65, page number 68078 dated November 14, 2000, or other emission trading credits approved 

for use in New Hampshire. 

2. DERs certified for reductions of nitrogen oxides (NOx) may be substituted for VOC reductions 

in a ratio of I :I, or an alternative ratio approved by DES and EPA. 

3. Annually by November 30, Webster Valve shall submit a report to DES on the projected use of 

credits for the upcoming year. This report shall meet the requirements ofEnv-A 3104.08, 

Notice of intent to Use DERs, including the following information: 

a. The name and location of the user; 

b. A copy of the Notice and Certification of Generation submitted by the generator source to 

the State (for paperwork reduction purposes, a certified statement that the notice is on file 

with DES will suffice); 

c. The protocol used to document the amount ofDERs needed to demonstrate compliance; and 
RACT Order No. ARDOl-001 

Webster Valve, Inc. 

March 21, 2007 

Page 5 of6 

d. Information that will allow DES to determine that Webster Valve is in compliance with 

Env-A 1400, Regulated Toxic Air Pollutants. 

4. Annually by April IS, Webster Valve shall submit a report to DES on the balance of credits for 

the previous calendar year. This report shall meet the requirements ofEnv-A 3104.09, Notice 

and Certification of Use, including the following information: 

a. The name and location of the owner or operator of the user source; 

b. The cost of the DERs; 

c. The amount ofDERs used and the associated serial numbers assigned by the DES; 

d. A calculation of the amount ofDERs required to demonstrate compliance with the emission 

limits stated in Part D, above. DERs shall be calculated on an annual basis by summing the 

monthly excess emissions as calculated in Part D.S, above. 

e. A statement that due diligence was made to verifY that the DERs were not previously used, 

and not generated as a result of actions prohibited under the regulations or other provisions 

of law; 

f. A statement that the DERs were not used in a manner prohibited under the regulation or 

other provisions of law; and 

g. A copy of the relevant Notice and Certification of Generation (for paperwork reduction 

purposes, a certified statement that the notice is on file with DES will suffice). 

h. The Notice of Certification of Use shall contain a certification by a responsible official of 

truth, accuracy and completeness and shall state that: 

(i) Based on information and belief formed after reasonable inquiry, the statements and 

information in the document are true, accurate and complete; and 

(ii) The user source is in compliance with all National Ambient Air Quality Standards, 

except ground level ozone, and all Ambient Air Limits for Regulated Toxic Air 

Pollutants. 

Please address any correspondence and communication in reference to this Order to the following: 

Ms. Barbara Dorfsclunidt 

NHDES, Air Resources Division 

Stationary Source Management Bureau 

29 Hazen Drive 

P.O. Box 95 

Concord, NH 03302-0095 

(603) 271-6796 
RACT Order No. ARD07-00J 

Webster Valve, Inc. 

March 21, 2007 

Page 6 of6 

Please address any correspondence and communication in reference to the ERCs orDERs to the 

following: 

Mr. Joe Fontaine 

NHDES, Air Resources Division 

29 Hazen Drive 

P.O. Box 95 

Concord, NH 03302-0095 

(603) 271-6794 

cc: Timothy Drew, PIP Office 

Ann Arnold, USEPA 

Town of Franklin 

Ken Boivin, GZA GeoEnvironmental 

Robert R. Scott 

Director 

Air Resources Division